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CFE — Tax Advisers Europe

CFE's Tax Top 5 – 6 April 2026

6 aprile 2026ANTI Redazione9 min di lettura

The European Commission published updated Data on Taxation Trends on 31 March 2026, providing a comprehensive dataset on taxation indicators across EU Member States. The dataset, now extending to 2024, produced by DG TAXUD in cooperation with national experts, supports analysis of tax systems by typ

BRUSSELS | 6 APRIL 2026

Latest EU Taxation Trends Data Show Evolving Revenue Patterns

The European Commission published updated Data on Taxation Trends on 31 March 2026, providing a comprehensive dataset on taxation indicators across EU Member States. The dataset, now extending to 2024, produced by DG TAXUD in cooperation with national experts, supports analysis of tax systems by type, economic function, and level of government, and feeds into the EU Semester and the forthcoming Annual Report on Taxation. In 2024, total tax revenues in the EU-27 reached €7.1 trillion, representing a 5.6% increase compared to 2023. However, strong nominal GDP growth of 4.4% resulted in only a modest rise in the overall tax-to-GDP ratio, which increased from 39.0% to 39.4%. Significant variation in tax burdens persists across Member States, with Denmark (45.2%), France (43.5%), and Austria (43.4%) recording the highest ratios, while Ireland (21.7%), Romania (27.9%), and Malta (28.8%) reported the lowest. The composition of tax revenues by economic function shows continued dominance of labour taxation. Revenues from labour taxes, including social contributions, increased by 6.6% in nominal terms, reflecting wage growth and a strong labour market, and now account for 51.5% of total tax revenue (up from 51.1% in 2023). Consumption taxes rose by 5.0%, while capital taxes increased by 4.1%, with weaker performance linked in part to stagnant property tax revenues. As a result, the relative shares of consumption and capital taxation declined slightly in 2024, to 26.8% and 21.6% respectively. The data indicate a continued structural reliance on labour taxation within EU tax systems, alongside comparatively slower growth in capital-based revenues. The dataset includes detailed indicators such as implicit tax rates, effective tax rates, and tax revenues by base and level of government, and covers all EU Member States as well as Iceland and Norway.

European Commission Clarifies OECD Side-by-Side Package Does Not Suspend Minimum Tax for US Companies

The European Commission has confirmed that the OECD “Side-by-Side Package” does not suspend the application of minimum tax rules to US companies, in response to a written parliamentary question. The question referred to reports that, as part of international negotiations on the OECD/G20 Pillar Two global minimum tax, the application of minimum tax instruments to US groups had been suspended from January 2026, and asked whether the Commission had carried out a quantitative assessment of the potential impact on Member States’ tax revenues and whether such analysis would be shared with the European Parliament. In his reply of 25 March 2026, Commissioner Hoekstra rejected this interpretation, stating that the Side-by-Side Package does not suspend minimum taxation for US companies. Commission Hoekstra explained that the agreement provides a coordination mechanism to ensure the coexistence of the US corporate tax framework, which includes rules designed to tax foreign profits at a minimum level, and the OECD/G20 Pillar Two standard. In this context, US groups operating in the EU remain subject to the qualified domestic minimum top-up tax implemented by Member States under the Minimum Taxation Directive. The Commission further indicated that the package is intended to establish a level playing field between jurisdictions and to prevent a “race to the bottom” in corporate taxation. This includes, in particular, a coordinated approach to the treatment of tax incentives and refundable tax credits, as well as mechanisms aimed at neutralising or mitigating the effects of large-scale subsidies granted by certain jurisdictions to multinational enterprises. At the same time, the framework allows EU Member States to maintain their existing levels of taxation. The Commission noted that it will assess the implementation and effects of the Side-by-Side Package at EU level, with this evaluation to be completed in line with the OECD’s broader stocktake of the global minimum tax framework, scheduled for 2029.

CFE Opinion Statement on the European Commission Call for Evidence on the Omnibus on Taxation

CFE Tax Advisers Europe has published an Opinion Statement in response to the European Commission’s Call for Evidence on the Omnibus on Taxation, which seeks to streamline and modernise key EU corporate tax directives. CFE welcomes the Commission’s focus on simplification and views the Omnibus initiative as a timely opportunity to improve the coherence and effectiveness of the EU direct tax framework. The current framework has developed through successive amendments and divergent national implementation, resulting in fragmentation, overlapping rules and increased compliance costs for cross-border businesses. These challenges have been further compounded by the introduction of the OECD global minimum tax (Pillar Two), which adds a further layer of interaction with existing EU rules. The CFE Opinion Statement identifies a number of structural and technical concerns. The Interest Limitation Rule (ILR), including the fixed 30% EBITDA ratio, produces procyclical and potentially distortionary outcomes in the current economic environment. The coexistence of ATAD Controlled Foreign Company (CFC) rules and the global minimum tax framework creates duplication, parallel calculations and risks of economic double taxation. Hybrid mismatch rules, particularly those relating to imported mismatches, impose significant administrative burdens and require extensive tracing and legal analysis across jurisdictions. Divergent interpretation and application of the General Anti-Abuse Rule (GAAR) and beneficial ownership concepts across Member States increase legal uncertainty and dispute risk. Administrative inefficiencies arising from fragmented and non-standardised procedures, including withholding tax relief systems, also continue to generate additional compliance costs and delays for cross-border activity. CFE in the response to the Commission Consultation calls for a coordinated simplification exercise. CFE recommends targeted reform of ATAD, in particular modernisation of the ILR through mechanisms such as carry-forward of disallowed interest, targeted carve-outs and revision of thresholds to reflect current economic conditions, as well as the introduction of a de jure SME carve-out to ensure proportionality. It also recommends addressing overlaps between CFC rules and Pillar Two, including through exclusion of in-scope groups or effective crediting mechanisms, and simplifying hybrid mismatch provisions supported by clearer EU-level guidance. CFE calls for the Commission to enhance consistency through alignment of GAAR wording and interpretation and reducing Member State optionality, as well as to improve coherence across corporate tax directives through harmonisation of thresholds, clarification of beneficial ownership standards and modernisation of entity definitions. The Statement also supports the digitalisation and standardisation of withholding tax procedures and calls for improvements to the functioning of the Tax Dispute Resolution Directive, including greater procedural clarity and timeliness. CFE is of the view that simplification of the EU tax framework would reduce compliance burdens, enhance legal certainty and support cross-border investment, while maintaining safeguards against tax avoidance. The Omnibus initiative provides an opportunity to deliver a more coherent, proportionate and effective framework through coordinated legislative and practical measures. CFE stands ready to engage further with the Commission concerning its submission.

OECD Publications on SME Financing, R&D Trends & Global Economic Outlook

Over the past week, the OECD released publications covering SME financing conditions, research and development trends, and the global economic outlook. The OECD published Financing SMEs and Entrepreneurs 2026: An OECD Scoreboard on 31 March 2026, providing data on SME financing trends across 48 countries. The report finds that, while borrowing conditions have begun to ease following a period of monetary tightening, SME financing costs remain elevated compared to pre-pandemic levels and lending conditions remain relatively stringent. New SME lending showed a modest recovery in 2024, increasing by 5.7% at the median, but overall loan stocks remain broadly stagnant and declined as a share of GDP in a majority of countries. Alternative financing instruments showed mixed performance, with factoring activity declining and leasing growing slightly. Venture capital investment increased in a number of countries, although activity remains concentrated in a limited number of large deals, particularly in artificial intelligence. The report also notes a growing role for fintech and non-bank lenders, alongside continued policy efforts to support diversification of SME financing sources. Also on 31 March 2026, the OECD released a statistical update on research and development (R&D) as part of the Main Science and Technology Indicators. The data indicate that inflation-adjusted R&D expenditure across the OECD grew by 2.6% in 2024, unchanged from 2023. The business sector accounted for 73% of total R&D spending, maintaining its dominant role. Growth patterns varied across regions, with stronger increases observed in the United States and several Asian economies, while growth in the European Union remained subdued. The release also highlights a decline in government budget allocations for R&D in 2024, with spending increasingly directed towards defence-related objectives. Globally, R&D expenditure is estimated to have reached USD 3.8 trillion in 2024, with the United States and China each reaching approximately USD 1 trillion. Earlier in the week, on 26 March 2026, the OECD issued the “OECD Economic Outlook, Interim Report March 2026: Testing Resilience”. The report projects global GDP growth of 2.9% in 2026 and 3.0% in 2027. It notes that global economic activity remained resilient prior to recent geopolitical developments, but that rising energy prices linked to disruptions in the Middle East are expected to increase inflation and weigh on growth. G20 inflation is projected at 4.0% in 2026, before easing to 2.7% in 2027. The report also outlines policy considerations, including the need for monetary policy vigilance, targeted fiscal support measures, and efforts to strengthen energy security and efficiency.

CFE Forum 2026: "Tax Policy Under Pressure: Strategy, Coherence & Trade-Offs" on 23 April 2026

The CFE Forum 2026 will take place on 23 April 2026 in Brussels under the theme “Tax Policy Under Pressure: Strategy, Coherence & Trade-Offs.” The Forum will examine how tax systems are responding to a range of structural pressures, including geopolitical tensions, renewed trade measures, increased cross-border mobility and evolving compliance and anti-money laundering frameworks. The programme will feature three panel discussions addressing key areas where trade-offs are emerging in practice. The first panel on global pressures on tax policy will include Benjamin Angel (European Commission), Daniel Bunn (Tax Foundation), Edwin Visser (PwC), a representative from the OECD and Helen Pahapill (UN Framework Convention on International Tax Cooperation), moderated by Saim Saeed (Bloomberg Tax) The second panel will focus on cross-border coherence between direct and indirect taxation, with speakers including Margaux Smets (Belgian Ministry of Finance), Jan-Willem Kunen (Loyens & Loeff), Trudy Perie (CFE), and Fernando Matesanz (International VAT Association), moderated by Jeremy Woolf (Pump Court Tax Chambers). The third panel will address ethics and transparency in a shifting regulatory landscape, including issues of professional privilege, DAC-related disclosure obligations and AML supervision. Speakers include Raluca Pruna (European Commission, DG FISMA), Henrik Paulander (European Commission, DG TAXUD), Ken Siong (IESBA), Aleksandar Ivanovski (CFE Tax Advisers Europe) and Johan Barros (Accountancy Europe), with moderation by Eduardo Gracia Espinar (Ashurst). The Forum will bring together policymakers, international organisations, tax administrations, academics and practitioners to consider how competing objectives such as simplification, competitiveness, revenue protection and transparency can be balanced in the design and governance of tax systems in Europe and beyond. Register now to secure your place.

The selection of the remitted material has been prepared by: Dr. Aleksandar Ivanovski & Brodie McIntosh


Fonte: CFE Tax Advisers Europe. Pubblicazione originale del 2026-04-06.

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